2024

January

RBA VAP Standard

Required Document List
Revision 8.0.1 – January 2024
Organizations working with and in the Responsible Business Alliance (RBA) are working
to improve sustainability and social responsibility within the global supply chain.

These companies recognize a mutual responsibility to ensure working conditions are

safe, workers are treated with respect and dignity, and that manufacturing practices are
environmentally responsible. The Validated Assessment Program (VAP) is a
collaborative approach to assessing to reduce the burden on supply chain companies
from multiple requests for social assessments. The VAP meets the need for a high quality,
consistent and cost-effective standard industry assessment for labor, ethics, health,
safety environmental, and management systems practices based on the RBA code of
conduct, laws, and regulations.

For more information about the Remote Validated Assessment Program (VAP), please
contact: RBA [email protected]

Responsible Business Alliance

1725 Duke Street, Suite 300, Alexandria VA 22314, USA

RBA VAP Resources webpage

RBA VAP Standard RBA Public January 2024

REQUIRED DOCUMENTS LIST
The following tables list the records and documents that the Assessors may review
during the Assessment. Be aware that these are minimum lists and do not cover all the
documents that may be required. The Assessors may request other related documents
and records for review either before or during the onsite Assessment.
• The items in the Critical Document List should be assembled in advance,
should the Lead Assessor request an advance copy of any of those items.
• The second table lists the minimum documents and records that must be made
available for the Assessors when they arrive on site.
• Documents may be uploaded into RBA-Online using the assessment
checklist functionality per (link) at the discretion of the Reviewee.
• The present list is indicative but not exhaustive; additional documents may
be requested by the assessor during the evaluation process to demonstrate
compliance.

General Notes
• Electronic HR records are acceptable during a VAP for review
• Original Permits and licenses under Health and safety should be seen in hard
copy by the assessor at the site
• Assessors retain the right to ask to see hard copies of all documentation,
printed copies of electronic records may constitute a hard copy.
• In accordance with GDPR guidelines documents should be submitted
ensuring that personal information is redacted for the purposes of
document submission.

RBA VAP Standard RBA Public January 2024

 Critical Document List
 Business license
 Facility lay out and floor plan
 Description/diagram of process
 Changes at facility in last 12 months
 Overview of production/services of last 12 months, volume, new equipment
 Organization chart with responsibilities
 Collective Bargaining agreement (current and valid if in place)
 Employee Handbook
 New worker training material
 Blank Employment Contract
 Workers Register including as much information as possible (Employee breakdown – by
position, nationalities, terms of employment (direct-hire, via labor agencies, student
worker, intern, …), accommodation provided
 ALL legal permits, licenses, authorizations
 Waivers from government agencies
 Valid management system certificates
 Last government submitted report (Labor, Ethics, Health & Safety, Environment)
 Risk Management Process (Labor, Ethics, Health & Safety, Environment)
 Emergency Response (all emergencies) and Business Continuity and Resumption plan
 Hazardous material inventory
 Hazardous waste inventory
 Corrective Action Plans (completed in last 12 months or in progress)

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Provision
General info General facility information
 Facility lay out and drawings
 Description of process and buildings within facility
 Changes at facility in last 12 months
 Overview of production/services of last 12 months, volume, new
equipment, new licenses
 Communication to workers of RBA Code provisions
 Communication with suppliers regarding RBA Code
conformance
 Contract requirements with suppliers regarding RBA Code
conformance
 Proof of verification suppliers’ implementation of RBA code
requirements

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Labor Provisions
A1 Prohibition of Forced Labor
 Contracts with labor agencies, labor brokers, labor service
providers
 Example of a worker (labor) contract
 Permanent employee
 Salaried employee
 Hourly paid, employee
 Temporary staff/worker
 Seasonal (if applicable) worker
 Juvenile employee
 Apprentice
 Foreign Migrant Worker (FMW)
 Vocational employee (if applicable)
 Records of employment including proof of age, identity, and
government worker permits
 Termination notice policy
 Recruitment/hiring process/procedure
 Documentation of employee loan and credit schemes
 Records of fees paid by workers (if applicable) for the last 24 months

A2 Young Workers
 Company policy for young worker protection and appropriate
hours/shifts
 Minimum hiring age policy
 Procedure for obtaining and validating proof of age
documentation
 Records of training and apprenticeship programs
 Child labor assistance/remediation process
 Juvenile worker protection procedures

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Labor Provisions
A3 Working Hours
 Non-traditional work hour permits, or overtime waivers issued by
government agencies
 Information provided to workers describing legal requirements for
working hours and overtime
 Working hours policy
 Process for allocating and controlling overtime hours
 Work time registration process/procedure
 Worker timecards or timesheets (most recent 12-month period)
 Evidence that employees have voluntarily agreed to overtime (e.g.,
signed statement)
 Evidence of communication of overtime
A4 Wages and Benefits
 Information provided to workers describing wages, deductions,
calculations, and benefits
 Information / examples of how wages were set for each job
code
 Disciplinary wage deductions and bonus award practices
 List of allowances, e.g. food, accommodations and procedure
 Procedure for piece rate determination and calculations (if applicable)
 List of worker contributions and procedure
 Local minimum wage definition
 Wage records or pay slips covering the last 12 months showing all
deductions, contributions, earnings, and money transfers for workers
 Records of contributions to the worker insurance schemes
 Payment records of contributions to worker insurance schemes
 Proof of purchase of all applicable insurance for workers
 Proof of maternity/paternity leave policy for workers
A5 Non-Discrimination/Non-Harassment/Humane Treatment
 Facility rules and regulations on acceptable worker practices and
disciplinary measures
 Disciplinary process/procedure
 Records of disciplinary actions
 Pre-employment, pre-placement medical examination
requirements
 Medical confidentiality procedure and practice
 Information on workers population (type
(contract/temporary/permanent), gender, function, ethnicity
(place of origin), age, ...)
 Current job advertisements and qualifications

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Labor Provisions
A5 continued.
 Procedure for workers to request reasonable religious
accommodation
 Religious accommodation records
 Procedure for workers to request reasonable accommodation for
disability
 Disability accommodation records

A6 Freedom of Association and Collective Bargaining

 Information provided to workers describing local laws and
regulations pertaining to freedom of association and labor
unions
 Minutes of worker meetings and/or union-management
meetings
 Evidence of regular communications and feedback channels with
workers to hear their issues and bring appropriate
resolutions
 Records of workers complaints and actions taken (and
communicated to workers)

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Health and Safety Provisions
B1 Occupational Health and Safety
 Safety procedures (e.g., lockout-tag out, confined space, hot-work
permit)
 Occupational health and safety permits, licenses and test reports.
 Personal protective equipment program and list of PPEs required for
various tasks
 Risk assessment records (mitigation evaluation, process and
administrative controls)
 Certificates of medical personnel, on-site clinic, …
 Records regarding measures taken to protect pregnant workers and
nursing mothers

B2 Emergency Preparedness
 Fire protection plan, maintenance records for fire protection,
firefighting system and fire alarm system
 Fire/evacuation drill records
 Chemical spill response drill records
 Maintenance records for emergency exits
 Emergency response, Business continuity and resumption plans
 Emergency Response Team (ERT) organization

B3 Occupational Injury and Illness

 Accident/occupational illness investigation and follow-up reports
 Injury / Illness logbook for the last 12 months
 “Near miss” log, analysis and follow up
 Absenteeism register

B4 Industrial Hygiene
 Industrial hygiene monitoring results for potential hazards in
the facility (noise, chemical, and physical agents,etc.)
 Medical surveillance results for workers involved in hazardous
work
 Hearing and respiratory protection programs
 Records of communication of industrial hygiene data to exposed
workers
 Chemical inventory records (including Industry Focus Process
Chemicals IFPC)

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Health and Safety Provisions
B5 Physically Demanding Work
 Records of evaluation of workers exposed to physically
demanding work
 Records of modifications made to work area or equipment
installed to alleviate manual stress to the worker
 Ergonomic risk assessment/manual handling risk assessment for
frequently repeated operations

B6 Machine Safeguarding
 Preventive maintenance records
 Records of machine safety risk assessments
 Process and procedures for evaluating worker exposure to the hazards
of manual handling, repetitive tasks, awkward postures, …
B7 Sanitation, Food, and Housing
 Canteen operation license and food handler health check records
 Food sample log
 Records of evacuation drills held in dormitory
 Records for monitoring of lightning, and conditioned environment.

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Environment Provisions
C1 Environmental Permits and Reporting
 Copies of permits for the facility’s operations and records of
inspections or citations
 Official exemptions from permit requirements, issued by
government agencies
 Records of monitoring, inspections and maintenance required by
environmental permits
 Environmental release registers (volume of water, air, waste) for
last 2 years
 Pollution prevention and reduction plans and results
 GHG initiatives and results
 Water conservation initiatives

C2 Hazardous Substances
 Inventories of chemicals and other hazardous materials
 Spill control plan and procedures
 MSDS’s for all hazardous materials on site
 Hazardous substance licenses/registrations
 Tank integrity inspection and test reports
 Records of hazardous waste shipping papers
 Waste vendor assessment reports

C3 Solid Waste
 List of solid wastes (hazardous and non-hazardous) generated on
site
 Consignment notes / disposal records (manifests, receipts,
invoices)
 Waste vendor licenses
 Waste permits or registrations and monitoring / inspection reports

C4 Air Emissions
 Air monitoring reports
 Air emission permit and reports submitted to regulatory
agencies
 Air pollution abatement equipment maintenance records
 Environmental noise monitoring reports

RBA VAP Standard RBA Public January 2024

Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Environment Provisions
C5 Water Management
 Facility map that includes outlines of storm water drainage
areas; locations of nearby bodies of water; location of storm
water collection and conveyances systems; outline of
impervious areas of the facility; location of where materials are
exposed to precipitation.
 Monitoring results of storm water discharges
 Wastewater treatment plant maintenance records and as- built
drawings
 Water quality analyses from water supply or groundwater
monitoring wells

C6 Energy Consumption and Greenhouse Gas Emissions

 Annual consumption/use of the following greenhouse gas
emission by type (Scope 1 and 2)
 Materiality assessment for significant scope 3 GHG categories
 Annual consumption of significant scope 3 categories

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Ethics Provisions
D1 No Improper Advantage
 Policy that ensures gifts to or from suppliers and customers is not
excessive in cost and frequency and hospitality, expenses or
promises
 Effective procedures for addressing its workers or agents
suspected of making or accepting improper offers of payments or gifts
and attempted bribery in all forms
 Investigation procedures and subsequent sanctions are applied are
in place
 Disciplinary procedures/policy
 Disciplinary records
D2 Disclosure of Information
 Non-disclosure agreement template/form
 Non-disclosure agreements with suppliers and customers
 Non-disclosure agreements with service providers

D3 Intellectual Property
 Intellectual property review and protection policies
D4 Fair Business, Advertising and Competition
 Annual financial report independently assessed by financial
assessment firm
 Fair business / anti collusion policy
 Advertising policy/communications policy
 Advert/job advert

D5 Protection of Identity and Non-Retaliation

 Policy/procedure on “whistle blowing”
 Clear communications to workers/employees on non-
retaliation.
 Procedures to investigate possible retaliation allegations.
D6 Privacy

 A formal policy and program to protect privacy:

 Training material and training records on privacy protection

RBA VAP Standard RBA Public January 2024

Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Management System Provisions (Note: a copy of the facility’s
management system description/manual could address a
Assessment number of the following information request). Below
Section requirements apply to each section (A. Labor, B. Health and
Safety, C. Environment, D.Ethics)
X.M.1 Risk Assessment (and Risk Management)

Legal and Customer Requirements

 Copy of customer requirements (e.g., RBA)
 Tracking system for monitoring of Social and Environmental
Responsibility (SER) laws, regulations, and implementation or
distribution logs.
 Copy of applicable laws

Risk Assessment and Risk Management

 Procedure to identify, evaluate and rank risks
 Records on risk assessment when a Significant Change occurred
 Listing of identified risks for the facility and risk assessment
review records
 Action plans addressing highest identified risks
X.M.2 Control Processes

Management Accountability and Responsibility

 Organizational chart
 Roles and responsibilities for the management system
representative, managers with human resources, ethics, labor,
health & safety and environment responsibility
 Records of management system reviews

Policies and Control Processes

 Company policies for corresponding section
 Control Procedures Implemented
 Training analysis
 Training calendar
 Training records
 Training evaluations

RBA VAP Standard RBA Public January 2024

Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Management System Provisions (Note: a copy of the facility’s management
system description/manual could address a number of the following
Assessment information request). Below requirements apply to each section (A. Labor,
Section B. Health and Safety, C. Environment, D.Ethics)

X.M.3 Communications

Communication
 Factory rules (for example, Employee Handbook)
 Process for communicating company SER performance and
expectations to workers, suppliers and customers

Worker Feedback, Participation and Grievance

 Information provided to workers and external stakeholders on
how to confidentially report business ethics issues of concern
 Policy/procedure on “whistle blowing”
 Procedure for confidential investigation and resulting actions on a
“whistle blow”
 Statistics on “whistle blowing"
 Description of formal ways for workers to participate in program
development and implementation (for example, committees, task
forces)
 Records of workers grievances, disciplinary investigations and
actions taken (and communicated)
 Worker surveys, complaints, and feedback provided by management

X.M.4 Performance Review and Continuous Improvement

Improvement Objectives
 Current year performance objectives and targets, including
results of periodic reviews of the implementation and status of
meeting the objectives
 Current improvement initiatives and progress status
Assessments
 Assessment process and procedure
 Copies of Assessments carried out in last 3 years
Corrective Action Process
 Corrective Action management procedure
 Copies of corrective action plans of Assessments carried out in last 3
years and current status against these corrective action plans

RBA VAP Standard RBA Public January 2024

Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Management System Provisions (Note: a copy of the facility’s
management system description/Manual could address a
Assessment number of the following information requests). Below
Section
requirements apply to each section (A. Labor, B. Health and
Safety, C.Environment, D.Ethics)

 Records of Nonconformance tracking, closure, status and

management reviews
 Legal compliance records of citations, penalties for violations of
labor / ethics laws and regulations
 Legal compliance records of EHS citations or penalties received in
the past 3 years

RBA VAP Standard RBA Public January 2024

 Minimum Documents and Records Available to Assessors On-Site (Start of the Assessment)
Assessment Section Supply Chain Management
E1 Company Commitment
 Labor, Employment, Ethics, Health & Safety and Environment
Policy
 Corporate Responsibility Policy - Company/facility’s Business Ethics or
Code of Business Conduct policy or manual

E2 Materials Restrictions
 Procurement and manufacturing specifications describing how the
facility meets legal and customer product content restrictions
 Records of communication of RoHS, REACH, WEEE and other customer
product content restrictions to suppliers
 Analytical test results
E3 Responsible Sourcing of Minerals
 Responsible sourcing of minerals policy/procedures
 Risk assessment of sources of materials are either 3TG + Cobalt free or
(if procured by the smelter/refinery site) are conflict‐free
 Action plans on information gathering/actions to ensure responsible
sourcing of minerals
 Due Diligence records related to 3TG + C for the last 2 years
E4 Supplier Responsibility
 Communication records with suppliers for RBA code requirements
 Contract terms and conditions requiring suppliers to conform to the RBA
code
 Next tier Major Supplier identification analysis
 Next tier Major Supplier/Labor Agent program
 On-site Major Supplier code conformance verification reports
 Corrective action plan for improvement areas identified in On- site
Major Supplier verification reports
 Working Hours and wage documentation for on-site service provider
workers, as appropriate

End of Document

RBA VAP Standard RBA Public January 2024